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Consistent with the preceding discussion, we shall grant
respondent's Motion to Dismiss for Lack of Jurisdiction.4
To reflect the foregoing,
An order of dismissal for
lack of jurisdiction will be
entered.
4 Although petitioners cannot pursue their case in this
Court, petitioners are not without a remedy. In short,
petitioners may pay the tax, file a claim for refund with the
Internal Revenue Service, and if the claim is denied, sue for a
refund in the Federal District Court or the Court of Federal
Claims. See McCormick v. Commissioner, 55 T.C. 138, 142 (1970).
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